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to individuals whose 1992-94 returns bore petitioner’s preparer
number. In the questionnaire respondent’s agent asked how much
the individuals had paid petitioner to prepare their returns.
The revenue agent received 151 responses to the questionnaire.
The responses stated that petitioner received fees from $0 to $70
per return. Based on the responses which indicated petitioner
prepared their returns, petitioner received an average return
preparation fee of $17 for 1992, $21 for 1993, and $28 for 1994.
Two people who responded to the questionnaire attached to
their responses records from their banks which showed that the
banks had paid petitioner a return preparation fee of $25 per
return in 1992, $28 per return in 1993, and $26 per return in
1994 and a $30 fee for every RAL for each of the years in issue.
Based on those two responses and third party bank records
attached to them, respondent’s agent estimated that petitioner
received an average return preparation fee of $25 for each return
he prepared in 1992, $28 for each return he prepared in 1993, and
$26 for each return he prepared in 1994. Respondent’s revenue
agent also assumed that petitioner received a $30 RAL fee for
each return he filed in 1992-94.
Respondent’s agent multiplied her estimate of petitioner’s
preparer fees and the $30 RAL fee by the number of returns
prepared and filed by petitioner for each year. Thus,
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